Coffee Pot Holding Corp. v. Commissioner

HOLMES, Circuit Judge.

This is a petition to review a decision .of the Board of Tax Appeals holding petitioner liable, as transferee, for jeopardy assessments of income tax, in the sum of approximately $330,000, owed by C. Perry Snell, the transferor. The Commissioner contended that Snell transferred substantially all of his assets, of a value greatly in excess of his tax liability, to the petitioner for an inadequate consideration, much too small to satisfy his tax debt. Petitioner argued -that it could not be required to pay, as transferee, because no attempt had been made to collect from…